Mr. Faraj and IC1, Just so you know I'll be out of the office next week for sexual assault training in Texas. I'm also out most of tomorrow recruiting. My cell is 630 862-4055, I'll be back in the office on Monday 27th, then out until the October 8th with wedding/honeymoon. Let me know if you need anything before the end of today. V/R LTJG Gough Charles C. Gough LTJG, JAGC, USN Naval Legal Service Office North Central Detachment Great Lakes 2540 Paul Jones Street, Bldg 2, Ste 100 Great Lakes, IL 60088 (847) 688-4753, extension 126 FOR OFFICIAL USE ONLY - Privacy Sensitive - Any misuse or unauthorized disclosure can result in both civil and criminal penalties. NOTICE: This e-mail communication is for the sole use of the intended recipient(s) and may contain unclassified confidential and/or attorney-client privileged information. Any unauthorized disclosure, copying or dissemination of this communication is prohibited. If you are not the intended recipient, please notify the sender by telephone or e-mail and delete all copies received. -----Original Message----- From: Gough, Charles C LTJG NLSO NC DET, GREAT LAKES Sent: Wednesday, September 15, 2010 14:06 To: 'Haytham Faraj' Subject: RE: Couple of Notes Ok, made the requested additions. Charles C. Gough LTJG, JAGC, USN Naval Legal Service Office North Central Detachment Great Lakes 2540 Paul Jones Street, Bldg 2, Ste 100 Great Lakes, IL 60088 (847) 688-4753, extension 126 FOR OFFICIAL USE ONLY - Privacy Sensitive - Any misuse or unauthorized disclosure can result in both civil and criminal penalties. NOTICE: This e-mail communication is for the sole use of the intended recipient(s) and may contain unclassified confidential and/or attorney-client privileged information. Any unauthorized disclosure, copying or dissemination of this communication is prohibited. If you are not the intended recipient, please notify the sender by telephone or e-mail and delete all copies received. -----Original Message----- From: Haytham Faraj [mailto:haytham@puckettfaraj.com] Sent: Wednesday, September 15, 2010 11:18 To: Gough, Charles C LTJG NLSO NC DET, GREAT LAKES Subject: RE: Couple of Notes The summary deal they offered includes rank and confinement protection as well as Board protection. If you could draft that into the PTA, I would appreciate it. I'd like to see if we can finish this up this week. Haytham Faraj, Esq. PUCKETT & FARAJ, PC _______________________ WASHINGTON DC METRO 1800 Diagonal Road Suite 210 Alexandria, VA 22314 703-706-0442 Phone DETROIT METRO 6200 Schaefer Road Suite 202 Dearborn, MI 48126 313-457-1390 Phone 202-280-1039 Fax www.puckettfaraj.com The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. -----Original Message----- From: Gough, Charles C LTJG NLSO NC DET, GREAT LAKES [mailto:charles.c.gough@navy.mil] Sent: Wednesday, September 15, 2010 12:14 PM To: Haytham Faraj Subject: RE: Couple of Notes OK, I just think based on the pleas, they will barely give her a slap on the wrist at a summary. Obviously I'm fine with that, so hopefully LCDR Clady is. Charles C. Gough LTJG, JAGC, USN Naval Legal Service Office North Central Detachment Great Lakes 2540 Paul Jones Street, Bldg 2, Ste 100 Great Lakes, IL 60088 (847) 688-4753, extension 126 FOR OFFICIAL USE ONLY - Privacy Sensitive - Any misuse or unauthorized disclosure can result in both civil and criminal penalties. NOTICE: This e-mail communication is for the sole use of the intended recipient(s) and may contain unclassified confidential and/or attorney-client privileged information. Any unauthorized disclosure, copying or dissemination of this communication is prohibited. If you are not the intended recipient, please notify the sender by telephone or e-mail and delete all copies received. -----Original Message----- From: Haytham Faraj [mailto:haytham@puckettfaraj.com] Sent: Wednesday, September 15, 2010 11:12 To: Gough, Charles C LTJG NLSO NC DET, GREAT LAKES Subject: RE: Couple of Notes If itâs not enough, then there is nothing we can do about it. They want a summary. One charge is sufficient for a conviction. They don't need 11. I think 11 is too many anyway. I'll discuss with LCDR Clady. Haytham Faraj, Esq. PUCKETT & FARAJ, PC _______________________ WASHINGTON DC METRO 1800 Diagonal Road Suite 210 Alexandria, VA 22314 703-706-0442 Phone DETROIT METRO 6200 Schaefer Road Suite 202 Dearborn, MI 48126 313-457-1390 Phone 202-280-1039 Fax www.puckettfaraj.com The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. -----Original Message----- From: Gough, Charles C LTJG NLSO NC DET, GREAT LAKES [mailto:charles.c.gough@navy.mil] Sent: Wednesday, September 15, 2010 11:55 AM To: Haytham Subject: RE: Couple of Notes Mr. Faraj, I attached a draft of the PTA with everything she says she can plea to. I am concerned that it won't be enough, but I'll defer to you. Please let me know where we should go from here. V/R, LTJG Gough Charles C. Gough LTJG, JAGC, USN Naval Legal Service Office North Central Detachment Great Lakes 2540 Paul Jones Street, Bldg 2, Ste 100 Great Lakes, IL 60088 (847) 688-4753, extension 126 FOR OFFICIAL USE ONLY - Privacy Sensitive - Any misuse or unauthorized disclosure can result in both civil and criminal penalties. NOTICE: This e-mail communication is for the sole use of the intended recipient(s) and may contain unclassified confidential and/or attorney-client privileged information. Any unauthorized disclosure, copying or dissemination of this communication is prohibited. If you are not the intended recipient, please notify the sender by telephone or e-mail and delete all copies received. -----Original Message----- From: Haytham [mailto:haytham@puckettfaraj.com] Sent: Tuesday, September 14, 2010 15:55 To: Gough, Charles C LTJG NLSO NC DET, GREAT LAKES Subject: Re: Couple of Notes Its a loser issue for us. The court will allow the government to change the names. She should plead "guilt except the word (wrong name) substituting therefor the words ( correct name), to the excepted words not guilty" Haytham Faraj 760-521-7934 Sent from my iPhone On Sep 14, 2010, at 1:23 PM, "Gough, Charles C LTJG NLSO NC DET, GREAT LAKES"<charles.c.gough@navy.mil> wrote: > Ok. How should we deal with the fact that the names are wrong? I don't want to tip our hand. Does it matter now that she's been arraigned? Maybe just say we can plea to these 11, lock them into a deal, then change the names? > > Charles C. Gough > LTJG, JAGC, USN > Naval Legal Service Office North Central Detachment Great Lakes 2540 > Paul Jones Street, Bldg 2, Ste 100 Great Lakes, IL 60088 > (847) 688-4753, extension 126 > > > FOR OFFICIAL USE ONLY - Privacy Sensitive - Any misuse or unauthorized disclosure can result in both civil and criminal penalties. > > NOTICE: This e-mail communication is for the sole use of the intended recipient(s) and may contain unclassified confidential and/or attorney-client privileged information. Any unauthorized disclosure, copying or dissemination of this communication is prohibited. If you are not the intended recipient, please notify the sender by telephone or e-mail and delete all copies received. > > -----Original Message----- > From: Haytham [mailto:haytham@puckettfaraj.com] > Sent: Tuesday, September 14, 2010 15:18 > To: Gough, Charles C LTJG NLSO NC DET, GREAT LAKES > Subject: Re: Couple of Notes > > Let's change the charge using exceptions and substitutions. They'll accept 11. > > Haytham Faraj > 760-521-7934 > Sent from my iPhone > > On Sep 14, 2010, at 1:02 PM, "Gough, Charles C LTJG NLSO NC DET, GREAT LAKES"<charles.c.gough@navy.mil> wrote: > >> Mr. Faraj, >> >> We are still scheduled for the trial the week of November 15th. Any change to that has to be done via your motion. The 39A session is set for 26 October. The judge instructed us to hold the October dates open. We reserved forum and pleas. >> >> Additionally, IC1 and I went through the new charges and the draft PTA. Of the 24 charges on the PTA, she can plea to 5 of them as written. On several of them, the government mixed up the names. They basically took the same charges from the first one, and put in the wrong names. Charge III spec 3 was said to vangrinsvin, not staley, Charge VIII spec 1 was said to Staley, not to brown, and charge VIII Spec 4 was said to brown, not Lynn. If you put in correct names, and change and/or delete some of the language (change "said to" to "said around" etc, she gets to 11, and they are the most innocuous ones. Not sure if thatâs going to be enough. What's your sense? >> V/R, >> LTJG Gough >> >> Charles C. Gough >> LTJG, JAGC, USN >> Naval Legal Service Office North Central Detachment Great Lakes 2540 >> Paul Jones Street, Bldg 2, Ste 100 Great Lakes, IL 60088 >> (847) 688-4753, extension 126 >> >> >> FOR OFFICIAL USE ONLY - Privacy Sensitive - Any misuse or unauthorized disclosure can result in both civil and criminal penalties. >> >> NOTICE: This e-mail communication is for the sole use of the intended recipient(s) and may contain unclassified confidential and/or attorney-client privileged information. Any unauthorized disclosure, copying or dissemination of this communication is prohibited. If you are not the intended recipient, please notify the sender by telephone or e-mail and delete all copies received. >> >> -----Original Message----- >> From: Haytham Faraj [mailto:haytham@puckettfaraj.com] >> Sent: Tuesday, September 14, 2010 8:53 >> To: Gough, Charles C LTJG NLSO NC DET, GREAT LAKES >> Subject: RE: PTA >> >> I may have failed to attach. Here it is. You may tell the judge that we are working on a deal. I do not agree to a December trial date and will be seeking a continuance if the case is scheduled for December. February is no longer available. The first week of March is available, however. Also please speak to LCDR Clady about his concern with IC1 Wofford not showing up to work. She sounded awful on the phone and she was clearly sick. >> >> Haytham Faraj, Esq. >> PUCKETT & FARAJ, PC >> _______________________ >> WASHINGTON DC METRO >> 1800 Diagonal Road >> Suite 210 >> Alexandria, VA 22314 >> 703-706-0442 Phone >> >> DETROIT METRO >> 6200 Schaefer Road >> Suite 202 >> Dearborn, MI 48126 >> 313-457-1390 Phone >> 202-280-1039 Fax >> >> www.puckettfaraj.com >> >> The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. >> >> >> -----Original Message----- >> From: Gough, Charles C LTJG NLSO NC DET, GREAT LAKES >> [mailto:charles.c.gough@navy.mil] >> Sent: Tuesday, September 14, 2010 8:23 AM >> To: Haytham Faraj >> Subject: RE: PTA >> >> Mr. Faraj, >> I didn't get anything attached. If the judge asks on our status, should I say we are working toward a deal, but still keep the October 29A on the docket? >> V/R, >> LTJG Gough >> >> Charles C. Gough >> LTJG, JAGC, USN >> Naval Legal Service Office North Central Detachment Great Lakes 2540 >> Paul Jones Street, Bldg 2, Ste 100 Great Lakes, IL 60088 >> (847) 688-4753, extension 126 >> >> >> FOR OFFICIAL USE ONLY - Privacy Sensitive - Any misuse or unauthorized disclosure can result in both civil and criminal penalties. >> >> NOTICE: This e-mail communication is for the sole use of the intended >> recipient(s) and may contain unclassified confidential and/or attorney-client privileged information. Any unauthorized disclosure, copying or dissemination of this communication is prohibited. If you are not the intended recipient, please notify the sender by telephone or e-mail and delete all copies received. >> >> -----Original Message----- >> From: Haytham Faraj [mailto:haytham@puckettfaraj.com] >> Sent: Monday, September 13, 2010 20:18 >> To: Wofford, Nikkia M ICC RTC; caramelfudge21@yahoo.com >> Cc: Gough, Charles C LTJG NLSO NC DET, GREAT LAKES >> Subject: PTA >> >> Here's the latest version of the PTA. As I said the government reneged on their NJP offer but are offering Summary court-martial with rank and confinement protection. Take a look and decide which of the charges you can plead guilty to. >> >> >> >> Haytham Faraj, Esq. >> >> PUCKETT & FARAJ, PC >> >> _______________________ >> >> WASHINGTON DC METRO >> >> 1800 Diagonal Road >> >> Suite 210 >> >> Alexandria, VA 22314 >> >> 703-706-0442 Phone >> >> >> >> DETROIT METRO >> >> 6200 Schaefer Road >> >> Suite 202 >> >> Dearborn, MI 48126 >> >> 313-457-1390 Phone >> >> 202-280-1039 Fax >> >> >> >> www.puckettfaraj.com <http://www.puckettfaraj.com/> >> >> >> >> The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender. >> You are required to purge this E-mail immediately without reading or making any copy or distribution. >> >> >>
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